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    Z. J. GIFTS v. CITY OF LITTLETON
                                            FILED
                               United States Court of Appeals
                                        Tenth Circuit
      
                                         NOV 18 2002
      
                                       PATRICK FISHER
                                            Clerk                                  PUBLISH
             
                               UNITED STATES COURT OF APPEALS
             
                                       TENTH CIRCUIT
             
             
             
             Z. J. GIFTS D-4, L.L.C., a Colorado No. 01-1220
              Limited Liability Company, doing    
              business as Christal's,             
                                                 
                  Plaintiff - Appellant,              
                                                 
             v.                                  
                                                 
             CITY OF LITTLETON, an Incorporated  
              Home Rule Municipal Corporation,    
                                                 
             Defendant - Appellee.               
                                                 
             
             
                        Appeal from the United States District Court
                                for the District of Colorado
                                    (D.C. No. 99-N-1696)
             
             
             
             Michael W. Gross (Arthur M. Schwartz with him on the briefs) of Schwartz & 
             Goldberg, P.C., Denver, Colorado for the Plaintiff-Appellant.
             
             J. Andrew Nathan (Heidi J. Hugdahl with him on the brief) of Nathan, Bremer, 
             Dumm & Myers, P.C., Denver, Colorado for the Defendant-Appellee.
             
             
             
             Before BRISCOE, Circuit Judge, BRORBY, Senior Circuit Judge, and 
             LUCERO, Circuit Judge.
             
             
             
             LUCERO, Circuit Judge.
             
             
             
             
     
                  This case raises several First Amendment issues, including one in which 
             the circuits are substantially divided:  namely, the extent to which prompt 
             judicial review must be assured in adult-business licensing cases.  Plaintiff Z.J. 
             Gifts D-4, L.L.C. ("ZJ") brought an action under 42 U.S.C.   1983 challenging 
             the City of Littleton's ("City's" or "Littleton's") adult business ordinance as 
             unconstitutional, seeking declaratory and injunctive relief, attorney's fees, and 
             damages.  The district court granted summary judgment to the City.  We have 
             jurisdiction under 28 U.S.C.   1291, and we reverse in part and affirm in part.
                                             I
                  In 1993, the City passed an ordinance requiring businesses that 
             specialize in adult entertainment or merchandise to obtain licenses, and 
             restricting those businesses to certain areas of Littleton.  Before passing its 
             ordinance, the City Council heard testimony and reviewed reports from other 
             cities concerning deleterious effects of adult businesses on property values 
             and on crime rates.
                  In the fall of 1999, ZJ opened its store, known as Christal's, on South 
             Broadway in Littleton.  Prior to the opening of Christal's, the City informed 
             the owner of the property on which Christal's was located that adult businesses 
             were not permitted at this South Broadway location.  In late August 
             1999-shortly before Christal's opened-ZJ filed a   1983 suit against the 
             City seeking monetary, declaratory, and injunctive relief.  ZJ's complaint
              
             alleged that Littleton's ordinance was unconstitutional because, among other 
             things, it infringed ZJ's First Amendment rights.  ZJ also alleged that it did not 
             intend to operate an "adult business establishment" as defined in Littleton's 
             ordinance.  (1 Appellant's App. at 11.)
                  On cross-motions for summary judgment, the district court ruled in favor 
             of the City, concluding that ZJ was covered by Littleton's ordinance and that 
             the ordinance was, in its entirety, constitutional.  After the district court's 
             decision in this case and during the briefing for this appeal, the City amended 
             its ordinance, clarifying certain corporate disclosure requirements and 
             changing an age restriction for adult businesses that do not offer live 
             entertainment.  Littleton, Colo., Ordinance 13 (2001) (codified at Littleton, 
             Colo., City Code   3-14-2, -5, -8, -16 (2002)).
                                             II
                  Both as originally enacted and as amended, Littleton's ordinance has two 
             primary functions:  (1) it requires all adult businesses within Littleton to 
             obtain licenses to operate within the City's borders, and (2) it restricts those 
             businesses to certain sections of the City and requires that they not locate 
             within a minimum distance of other specified sites.
                  Among the adult businesses covered by Littleton's ordinance, Christal's 
             would most likely qualify as an "adult bookstore, adult novelty store, or adult 
             video store."    Littleton, Colo., City Code   3-14-2.  A commercial
              
             establishment falls into this category if, as judged by percentage of stock-in-
             trade, revenue, or advertising, it is primarily devoted to the sale of materials 
             that are characterized by the depiction or description of "specified sexual 
             activities" or "specified anatomical areas," regardless of whether the 
             establishment has other business purposes.  Id.   "Specified anatomical areas" 
             are further defined as:  "(A) Less than completely and opaquely covered human 
             genitals, pubic region, buttocks, anus or female breasts below a point 
             immediately above the top of the areolae; or (B) Human male genitals in a 
             discernibly turgid state, even if completely and opaquely covered."  Id. 
             "Specified sexual activities" are defined to include masturbation, fondling of 
             the genitals and other specified areas, excretory functions, human genitals in a 
             state of "sexual stimulation, arousal or tumescence," and "normal or perverted" 
             sex acts.  Id.
                  No adult business covered by Littleton's ordinance may operate within 
             five-hundred feet of a church, school, child-care facility, public park, massage 
             parlor regulated by local ordinances, or community correctional facility.  Id.   
             3-14-3.  Adult businesses also may not operate within one-thousand feet of 
             each other or a massage parlor regulated by state law.  Id.  In addition, multiple 
             adult businesses may not operate within the same structure.  Id.
                  Under Littleton's ordinance, operation of an adult business within the 
             City requires a license.  Among other things, a license application must
              
             indicate or provide:  names of all owners, managers, and employees of the 
             business; information about whether the applicant has had an adult-business 
             license denied, revoked, or suspended by any jurisdiction; an indication 
             whether the applicant has adult-business licenses from other jurisdictions; the 
             address, driver's license number, and social security number of the applicant 
             and all owners, managers, and employees; a floor plan for the proposed 
             business; a written statement by the City's Zoning Officer that the proposed 
             location is in compliance with the ordinance; and a statement of whether an 
             owner, manager, or employee of the business has been convicted of specified 
             criminal acts.(1)  Id.   3-14-5.  Certain specified persons must also be 
             fingerprinted and photographed by the Police Department.  Id.
                  After an application has been submitted, the City Clerk has thirty days to 
             approve or deny the license.  Id.   3-14-8.  The Clerk may deny an application 
             for one or more specified reasons, including:  the applicant is under twenty-
             one years old; the applicant has made a false statement on the application; the 
             applicant or any owner has had an adult-business license revoked or suspended 
             within Colorado in the past year; the applicant has operated an adult business 
             deemed to be a public nuisance in the past year; a corporate applicant is not in
             
    
    
             (1)       In amending its ordinance in 2001, the City added more specific 
             corporate disclosure requirements, but did not significantly alter the key 
             provisions.  Littleton, Colo., Ordinance 13 (2001).
              
             good standing or authorized to conduct business in Colorado; the applicant is 
             overdue in any city taxes, fees, fines, or penalties assessed in relation to an 
             adult business; the applicant has failed to obtain the required sales-tax license; 
             or the applicant has been convicted of specified criminal acts.  Id.  Specified 
             criminal acts for the purposes of the ordinance are defined as:  "Sexual crimes 
             against children, sexual abuse, rape or crimes connected with another adult 
             business, including distribution of obscenity, prostitution, pandering or tax 
             violation."  Id.   3-14-2.
                  If the clerk denies the application, the applicant then has twenty days to 
             appeal the denial to the City Manager,(2) who must hold a hearing within thirty 
             days.  Id.   3-14-8.  If that appeal is denied, the applicant may seek review in 
             state court pursuant to Colorado Rule of Civil Procedure 106(a)(4).  Id.
                  Licenses are issued for one-year terms and may be renewed only by filing 
             a renewal application.  Id.    3-14-9, -10.  Licenses may be suspended for one 
             or more specified grounds.  Id.   3-14-11.  Suspension or revocation may only 
             occur after a hearing before the City Manager and may be appealed to state 
             court.  Id.  Finally, under the amended ordinance, all adult businesses in
             
    
    
             (2)       This is the time limit under the amended ordinance.  Before the 
             amendments, the ordinance gave the applicant only ten days to request a hearing 
             before the City Manager.  Littleton, Colo., Ordinance 27 (1993).
              
             Littleton that do not provide live entertainment are required to restrict 
             entrance to individuals who are eighteen or older.(3)  Id.   3-14-16.
                                            III
                  We initially determine whether there is an Article III case or controversy 
             before us.  Essence, Inc. v. City of Fed. Heights, 285 F.3d 1272, 1280 (10th 
             Cir. 2002).  Standing is an essential part of the case-or-controversy 
             requirement of Article III.  Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 
             (1992).  There are three elements to Article III standing:  (1) injury-in-fact, (2) 
             causation, and (3) redressability.  Essence, 285 F.3d at 1280.  An injury-in-fact 
             is an "`invasion of a legally protected interest' that is (a) concrete and 
             particularized and (b) actual or imminent, i.e., not conjectural or hypothetical." 
             Id. (quoting Defenders of Wildlife, 504 U.S. at 560).  Causation requires a 
             showing that the injury is "`fairly trace[able] to the challenged action of the 
             defendant,' rather than some third party not before the court."  Id. (quoting 
             Defenders of Wildlife, 504 U.S. at 560).  Redressability means that it is "likely 
             that a favorable court decision will redress the injury of the plaintiff."  Id. 
             "The burden to establish standing rests on the party invoking federal 
             jurisdiction."  Id.  When the case has been resolved in the district court on 
             summary judgment grounds, "`a plaintiff must establish that there exists no
             
    
    
             (3)       Under the original ordinance, admission to all adult businesses was 
             limited to persons over twenty-one.  Littleton, Colo., Ordinance 27 (1993).
              
             genuine issue of material fact as to justiciability,' and `mere allegations' of 
             injury, causation, and redressability are insufficient."  Id. (quoting Dep't of 
             Commerce v. United States House of Representatives, 525 U.S. 316, 329 
             (1999)).
                                             A
                  Standing usually requires that the plaintiff assert an injury to himself, 
             rather than injuries to third parties not before the court.  However, this rule is 
             not strictly enforced in the context of facial challenges to laws as violative of 
             the First Amendment, even though a facial challenge to the validity of a statute 
             necessarily entails a challenge to the statute as applied to third parties besides 
             the plaintiff:
                  In the area of freedom of expression it is well established that one 
                  has standing to challenge a statute on the ground that it delegates 
                  overly broad licensing discretion to an administrative office, 
                  whether or not his conduct could be proscribed by a properly drawn 
                  statute, and whether or not he applied for a license.
             
             Freedman v. Maryland, 380 U.S. 51, 56 (1965); see also FW/PBS, Inc. v. City 
             of Dallas, 493 U.S. 215, 223 (1990) (opinion of O'Connor, J.) ("Although 
             facial challenges to legislation are generally disfavored, they have been 
             permitted in the First Amendment context where the licensing scheme vests 
             unbridled discretion in the decisionmaker and where the regulation is 
             challenged as overbroad.").  "A form of unbridled discretion is the failure to 
             place brief, specific time limits on the decision-making process."  Nightclubs,
              
             Inc. v. City of Paducah, 202 F.3d 884, 889 (6th Cir. 2000); see also FW/PBS, 
             493 U.S. at 22324 (opinion of O'Connor, J.) (stating that unbridled discretion 
             includes licensing schemes that create a "`risk of delay' such that `every 
             application of the statute creates an impermissible risk of suppression of 
             ideas'" (quotations omitted)).
                  Littleton's ordinances include within their purview sexually explicit 
             speech, and the City does not contest that this speech is protected by the First 
             Amendment.  ZJ's challenge to Littleton's licensing system is based both on a 
             claim that the City vests too much discretion in licensing officials in granting 
             or denying a license, and that the system creates a risk of delay in granting or 
             denying a license.  Thus, ZJ has standing to bring a facial challenge to the 
             licensing system on these two grounds.
                  It is true that the overbreadth doctrine discussed above "does not 
             eliminate the need for the plaintiff to demonstrate its own cognizable injury in 
             fact."  Nat'l Council for Improved Health v. Shalala, 122 F.3d 878, 883 (10th 
             Cir. 1997).  But this requirement is satisfied where the plaintiff is engaged "in 
             a course of conduct arguably affected with a constitutional interest, but 
             proscribed by a statute, and there exists a credible threat of prosecution." 
             Babbitt v. United Farm Workers Nat'l Union, 442 U.S. 289, 298 (1979).  Such 
             a plaintiff need not wait until an actual criminal prosecution has begun.  Id.
     
                  ZJ's business depends in part on its ability to sell materials that are 
             protected by the First Amendment.  ZJ has alleged in its complaint that the City 
             views it as an adult business that is in violation of the licensing requirements 
             of the ordinance, and it has also presented a letter from the City denying ZJ's 
             sales-tax license application because ZJ's business "may be categorized as an 
             adult business."  (3 Appellant's App. at 450.)   ZJ has thus adequately shown 
             that, at least from the City's perspective, its business is proscribed by the 
             ordinance.
                  Finally, the City has proceeded with a civil complaint in state court 
             against ZJ for violation of the ordinance based on ZJ's failure to apply for an 
             adult-business license and ZJ's operation of an adult business without a 
             license.(4)  While ZJ's sales-tax license application was denied and a civil 
             complaint was brought in state court only after ZJ's federal complaint was 
             filed, these events nonetheless are evidence that when ZJ filed its lawsuit there 
             was "a credible threat of prosecution" under Littleton's ordinance and that the 
             threat of prosecution continues.  Babbitt, 442 U.S. at 298; see also id. at 302 
             (indicating that standing exists "when fear of criminal prosecution under an
             
    
    
             (4)       In supplemental briefing the City explicitly waived the applicability of 
             abstention under Younger v. Harris, 401 U.S. 37 (1971).  A state may 
             voluntarily submit to federal jurisdiction even though it might have had a 
             tenable claim for abstention.  See Ohio Civil Rights Comm'n v. Dayton 
             Christian Sch., Inc., 477 U.S. 619, 626 (1986) (citing cases in which Younger 
             abstention was waived).
              
             allegedly unconstitutional statute is not imaginary or wholly speculative").  ZJ 
             has satisfied the injury-in-fact requirement because the City has taken steps to 
             enforce the ordinance against ZJ.(5)
                                             B
                  ZJ also has standing to challenge the location requirements in Littleton's 
             ordinance.  Both parties agree that ZJ's business is located on a site in which 
             adult businesses are not permitted under the ordinance.  Based on the location 
             of ZJ's business, the City has refused to grant ZJ a sales-tax license, and the 
             City's complaint in state court is based in part on the location of ZJ's business. 
             This is sufficient evidence for ZJ to meet the injury-in-fact requirement.  By 
             enacting and enforcing its ordinance, the City brought about ZJ's injury, and 
             injunctive and declaratory relief, if granted by this court, would redress ZJ's injury.
                                             C
                  ZJ has challenged the provisions in Littleton's ordinance that require the 
             City to reject adult-business license applications when the applicant has been 
             convicted of specified past criminal acts.  ZJ has never alleged that these 
             restrictions would apply to any of the owners or operators of ZJ's business.  ZJ 
             therefore has not even argued that it might be affected by these provisions in 
             Littleton's ordinance, and accordingly it does not have standing to challenge 
             these provisions.  See FW/PBS, 493 U.S. at 234 (stating that for a party to have 
             standing to challenge a similar provision in a Dallas ordinance, "the individual 
             must show both (1) a conviction of one or more of the enumerated crimes, and 
             (2) that the conviction or release from confinement occurred recently enough 
             to disable the applicant under the ordinance").
                  ZJ also attacks the ordinance's license revocation and suspension 
             provisions.  ZJ, however, has never obtained a license from the City, nor has it 
             indicated that it plans to obtain a license.  Instead, ZJ stated in its complaint 
             that it "does not intend to operate an adult entertainment establishment in a B-2 
             zone."  (1 Appellant's App. at 11.)  ZJ has neither alleged nor provided any 
             evidence that the licensing suspension or revocation proceedings will apply to 
             it.  As it is "pure conjecture," Essence, 285 F.3d at 1281, whether ZJ will be 
             forced to comply with these provisions of the ordinance, ZJ likewise does not
             (5)       While ZJ has never applied for an adult-business license, this is not a 
             requirement for standing to mount a facial challenge against an ordinance.  See 
             ACORN v. Municipality of Golden, 744 F.2d 739, 744 (10th Cir. 1984) 
             ("Applying for and being denied a license or an exemption is not a condition 
             precedent to bringing a facial challenge to an unconstitutional law.").
                  ZJ, the City argues, has no standing to challenge the licensing 
             requirements of the ordinance becauseeven if such a challenge were 
             successfulZJ would nonetheless be in violation of the location requirements 
             of the ordinance.  However, ZJ challenges both sets of requirements, and if 
             both challenges are successful, then ZJ will obtain its desired relief.  See N. 
             Ave. Novelties, Inc. v. City of Chicago, 88 F.3d 441, 443-44 (7th Cir. 1996). 
             In addition, the parties' supplemental briefs reveal that the City is charging ZJ 
             with separately violating both the licensing and location requirements.  Thus, 
             even if ZJ only succeeds in its challenge to the licensing provisions, it will 
             nonetheless obtain some relief against prosecution by the City.
              
             have standing to challenge these provisions.  Cf. id. (holding that an adult 
             business did not have standing to 
             challenge a city's provisions for the granting of a license because the business 
             already had a license and had not alleged any facts indicating that it would need 
             to reapply for a license).
                                             D
                  ZJ decries as overly vague the ordinance's definition of an "adult 
             bookstore, adult novelty store, or adult video store" as a business that "devotes 
             a significant or substantial portion" of its floor space, inventory, or advertising 
             to adult materials, or that obtains "a significant or substantial portion" of its 
             revenue from those materials.  Littleton, Colo. City Code   3-14-2.
                  In the First Amendment context, the Supreme Court has determined that a 
             plaintiff may have standing to challenge a statute as overly vague with respect 
             to third parties even if the suspect statute is "unquestionably applicable" to the 
             plaintiff.  Young v. Am. Mini Theatres, Inc., 427 U.S. 50, 5960 (1976) ("On 
             several occasions we have determined that a defendant whose own speech was 
             unprotected had standing to challenge the constitutionality of a statute which 
             purported to prohibit protected speech, or even speech arguably protected."). 
             This "exception from traditional rules of standing" reflects the Supreme 
             Court's judgment that "the very existence of some statutes may cause persons
              
             not before the Court to refrain from engaging in constitutionally protected 
             speech or expression."  Id. at 59 60.(6)
                  Nevertheless, as the Court in Young explained, "if the statute's deterrent 
             effect on legitimate expression is not both `real and substantial,' and if the 
             statute is `readily subject to a narrowing construction by the state courts,' the 
             litigant is not permitted to assert the rights of third parties."  Id. at 60 (citation 
             omitted, quoting Erznoznik v. City of Jacksonville, 422 U.S. 205, 216 (1975)). 
             
                  In Young, the Court concluded that the ordinance in question did not have 
             a "real and substantial" deterrent effect on legitimate expression because 
             "there is surely a less vital interest in the uninhibited exhibition of material 
             that is on the borderline between pornography and artistic expression than in 
             the free dissemination of ideas of social and political significance."  Id. at 61. 
             The same rationale applies equally to the present case.  Adult businesses 
             covered by Littleton's ordinance are, by definition, likely to carry materials 
             that border on pornography.  Stated simply, in light of Young, Littleton's ordinance does 
    	 not have a "real and substantial" deterrent effect upon 
             "legitimate expression."
                  As to the second issue raised by Young-whether the ordinance is readily 
             subject to a narrowing construction- we note that language similar to the 
             "significant or substantial" language used in this ordinance has been interpreted 
             previously by state courts in a sufficiently narrow manner to avoid 
             constitutional problems.  A common method of narrowing construction has 
             been to develop a percentage that will act as a guide as to what constitutes 
             "significant or substantial."  See, e.g., Dandy Co. v. Civil City of South Bend, 
             401 N.E.2d 1380, 138586 (Ind. Ct. App. 1980) (holding that a conviction 
             under a similar ordinance was sustainable where there was evidence that "50 to 
             80% of the inventory was adult in nature"); St. Louis County v. B.A.P., Inc., 25 
             S.W.3d 629, 63031 (Mo. Ct. App. 2000) (noting that a local adult-business 
             ordinance established a rebuttable presumption that a business carries "a 
             substantial portion" of adult-oriented items where more than twenty-five 
             percent of the retail value of the inventory consists of such items); City of 
             New York v. Les Hommes, 724 N.E.2d 368, 370 (N.Y. 1999) (noting that the 
             City of New York had clarified that a "substantial portion" for purposes of its 
             (6)       Having reviewed the evidence provided by the parties in the present 
             case, including the videotape of the interior of ZJ's business, we conclude that 
             the ordinance is "unquestionably applicable" to ZJi.e., a "significant or 
             substantial" portion of ZJ's stock-in-trade, interior floor space, or revenue is 
             devoted to material that is "characterized by the depiction or description" of 
             the defined "specified sexual activities" or "specified anatomical areas."
              
             adult-business ordinance meant at least forty percent).  We conclude that "the 
             limited amount of uncertainty in the ordinance[] is easily susceptible of a 
             narrowing construction."  Young, 427 U.S. at 61.
                   In short, we agree with the district court that ZJ "does not have standing 
             to challenge the constitutionality of [Littleton's ordinance] under the void for 
             vagueness doctrine."  (3 Appellant's App. at 561.)
                                             E
                  Finally, Littleton's ordinance as originally enacted prohibited individuals 
             under twenty-one years of age from being licensees, owners, managers, 
             employees, or customers of an adult business.  ZJ argues that it is 
             unconstitutional to restrict individuals between the ages of eighteen and 
             twenty-one from entering or working in its business.  We need not address ZJ's 
             challenge to the age restrictions, however, because the City has amended its 
             ordinance to provide that anyone over eighteen years of age may enter an adult 
             business that does not offer live entertainment.(7)  Thus, ZJ's challenge to the 
             age restrictions on customers and employees of its business is now moot, and 
             we will not address it.
                                             IV
                  We now address ZJ's claims that Littleton's licensing scheme grants 
             excessive discretion to licensing officials.
    
    
    
             (7)       To the extent that other provisions of Littleton's ordinance conflict 
             with this amendment, they have been repealed.  Littleton, Colo., Ordinance 13, 
             9 (2001).
              
                  Because this case was decided on summary judgment, we review the 
             district court's decision de novo, applying the same legal standard as the 
             district court.  Simms v. Oklahoma ex rel. Dep't of Mental Health & Substance 
             Abuse Servs., 165 F.3d 1321, 1326 (10th Cir. 1999).  Summary judgment is 
             appropriate "if the pleadings, depositions, answers to interrogatories, and 
             admissions on file, together with the affidavits, if any, show that there is no 
             genuine issue as to any material fact and that the moving party is entitled to a 
             judgment as a matter of law."  Fed. R. Civ. P. 56(c) para. 4.  "When applying 
             this standard, we view the evidence and draw reasonable inferences therefrom 
             in the light most favorable to the non-moving party."  Simms, 165 F.3d at 1326. 
             "If there is no genuine issue of material fact in dispute, we determine whether 
             the district court correctly applied the substantive law."  Id.  In the First 
             Amendment context, "[o]ur review of the record is more rigorous," and we are 
             "obligated to make an independent examination of the record in its entirety." 
             Essence, 285 F.3d at 1283 (quotation omitted).
                  Littleton's ordinance requires all adult businesses to obtain a license 
             prior to opening for business.  "Adult businesses," as defined by the ordinance, 
             include adult bookstores and adult video stores, see Littleton, Colo., City Code 
               3-14-2, that sell materials presumptively protected by the First Amendment.(8)
             
    
    
             (8)       In the instant case, the City does not argue that the materials sold by 
    	 "adult businesses" are obscene and therefore unprotected by the First 
             Amendment.  The City has therefore effectively made the same concession that 
             the City of Dallas made in FW/PBS:  i.e., that the ordinance applies to 
             businesses that purvey speech protected by the First Amendment.  See FW/PBS, 
             493 U.S. at 224 (noting that the Dallas ordinance largely targeted businesses 
             that purvey sexually explicit speech and no claim was made that such materials 
             were unprotected by the First Amendment).
              
             A very similar licensing scheme was analyzed as a "prior restraint" on speech 
             by six of the Justices of the Supreme Court in FW/PBS.  493 U.S. at 22530 
             (opinion of O'Connor, J.); id. at 238 (Brennan, J., concurring).  Following 
             FW/PBS, we have concluded that "licensing of adult entertainment 
             establishments" must be analyzed as a prior restraint.  Essence, 285 F.3d at 
             1289 90.
                  Ordinarily, a duly enacted law is presumed to be constitutional.  When a 
             law infringes on First Amendment rights, however, the proponent of the law 
             bears the burden of establishing its constitutionality.  Wilson v. Stocker, 819 
             F.2d 943, 949 (10th Cir. 1987).  Whether or not Littleton's ordinance is 
             content-neutral is not relevant to the burden of proof, because any "system of 
             prior restraint" comes to this court "bearing a heavy presumption against its 
             constitutional validity."  FW/PBS, 493 U.S. at 225 (quotation omitted).  In the 
             present case, therefore, the City bears the burden of establishing that 
             Littleton's ordinance is constitutional.
                                              A
                  Standards for analysis of a prior restraint of speech were initially 
             developed in the context of censorship schemes in Freedman, where the 
             Supreme Court held that (1) a censorship scheme must assure the exhibitor, "by 
             statute or authoritative judicial construction, that the censor will, within a 
             specified brief period, either issue a license or go to court to restrain showing 
             the film"; (2) the censorship scheme must "assure a prompt final judicial 
             decision" following a refusal to license; and (3) "the burden of proving that the 
             film is unprotected expression must rest on the censor."  380 U.S. at 5859. 
                  In FW/PBS, a divided Supreme Court considered whether Freedman's 
             procedural requirements applied to adult-business licensing schemes as well. 
             Two Justices joined Justice O'Connor in announcing the judgment of the Court 
             that the Dallas licensing scheme at issue was unconstitutional.  FW/PBS, 493 
             U.S. at 229.  Three other Justices concurred but would have gone further in 
             applying the Freedman requirements.  Id. at 238 39 (Brennan, J., concurring). 
             Justice O'Connor's opinion characterizes Freedman as mandating that any prior 
             restraint "that fails to place limits on the time within which the decisionmaker 
             must issue the license is impermissible," FW/PBS, 493 U.S. at 226, because a 
     
             "scheme that fails to set reasonable time limits on the decisionmaker creates 
             the risk of indefinitely suppressing permissible speech," FW/PBS, 493 U.S. at 227.  
    	 The Court in FW/PBS determined that the Dallas ordinance failed to meet 
             this general 
             requirement because a license could not be approved without inspection and 
             approval by the fire department, the health department, and the building official 
             as being in compliance with relevant laws and ordinances.  Id.  Even though a 
             completed license application had to be approved or disapproved within thirty 
             days after submission, there was nonetheless a risk that the city could 
             endlessly delay those inspections and approvals in order to postpone 
             consideration of a license application because there was no time limit for the 
             inspections and approvals.  Id.  Concluded the Court:  "Thus, the city's 
             regulatory scheme allows indefinite postponement of the issuance of a 
             license."  Id.
                  Justice O'Connor then reiterated the Freedman procedural requirements:
                  [T]he following three procedural safeguards were necessary to 
                  ensure expeditious decisionmaking by the motion picture 
                  censorship board: (1) any restraint prior to judicial review can be 
                  imposed only for a specified brief period during which the status 
                  quo must be maintained; (2) expeditious judicial review of that 
                  decision must be available; and (3) the censor must bear the burden 
                  of going to court to suppress the speech and must bear the burden 
                  of proof once in court.
             
             Id. at 227.  Concluding that the "first two safeguards are essential" to 
             preventing undue delay in the licensing process, id. at 228, and that the Dallas 
             licensing scheme "fails to provide an avenue for prompt judicial review" of a
              
             license denial, id. at 229, Justice O'Connor's opinion held that Freedman's 
             third requirement-that the censor bear the burden of obtaining judicial action 
             and of proof-need not be applied in the context of adult-business licensing 
             schemes.  Id. at 230. 
                  The remainder of the Court was sharply divided.  Justice Brennan, joined 
             by two other Justices, agreed that the Dallas ordinance was an unconstitutional 
             prior restraint, but would have applied all three of the Freedman procedural 
             requirements.  Id. at 23839 (Brennan, J., concurring).  Justice White, joined 
             by the Chief Justice, concluded that the Dallas ordinance was constitutional and 
             that none of the Freedman procedural requirements applied because the 
             ordinance was not a prior restraint.  Id. at 245 (White, J., concurring and 
             dissenting).  Justice Scalia concurred in part and dissented in part on other 
             grounds.  Id. at 250 (Scalia, J., concurring and dissenting).
                  Faced with the fractured decision in FW/PBS, our sibling courts of 
             appeals have struggled to determine which of Freedman's requirements apply to 
             licensing schemes.  Joined by several other circuits, we have concluded that the 
             first two Freedman requirements-maintenance of the status quo and 
             expeditious judicial review-are applicable to the licensing context.  See 
             Essence, 285 F.3d at 1290; see also, e.g., Baby Tam & Co. v. City of Las Vegas, 
             154 F.3d 1097, 1100 01 (9th Cir. 1998); 11126 Baltimore Boulevard, Inc. v. 
             Prince George's County, 58 F.3d 988, 996 & n.12 (4th Cir. 1995); TK's Video,
              
             Inc. v. Denton County, 24 F.3d 705, 70708 (5th Cir. 1994).  With respect to 
             Freedman's third requirement-that the censor must bear the burden of going 
             to court and of proof-our circuit has not yet decided whether it is applicable 
             to adult-business licensing schemes.  See Essence, 285 F.3d at 1290 n.17. 
             Other circuits, however, have held that the third requirement of Freedman does 
             not apply to licensing schemes that do not directly regulate content.  See 
             MacDonald v. City of Chicago, 243 F.3d 1021, 103536 (7th Cir. 2001); Ward 
             v. County of Orange, 217 F.3d 1350, 1355 (11th Cir. 2000); Steakhouse, Inc. v. 
             City of Raleigh, 166 F.3d 634, 640 41 (4th Cir. 1999).   Because ZJ does not 
             argue that the Littleton ordinance fails to satisfy the third Freedman 
             requirement, we limit our analysis here to the two procedural safeguards 
             clearly adopted in FW/PBS.
                                             B
                  Our first inquiry is whether Littleton's ordinance satisfies the 
             requirement that "any restraint prior to judicial review can be imposed only for 
             a specified brief period during which the status quo must be maintained." 
             FW/PBS, 493 U.S. at 227.  Although the ordinance specifies that a license 
             application must be approved within thirty days, Littleton, Colo., City Code   
             3-14-8, ZJ stresses that, before an application is accepted, (1) applicants are 
             required to obtain a written statement from the City's Zoning Official stating 
             that the proposed location is in compliance with the location requirements of
              
             the ordinance, (2) specified persons named on the application must be 
             fingerprinted and photographed by the Police Department,(9) and (3) the applicant 
             must obtain a sales-tax license.  ZJ argues that these provisions present the 
             possibility of indefinite postponement of a license.  Id.
                  Justice O'Connor's opinion in FW/PBS, which announced the judgment 
             of the Court, held that the Dallas ordinance in question allowed for indefinite 
             postponement of a license because the premises had to be approved in advance 
             by "the health department, fire department and the building official."  493 U.S. 
             at 227.  Although the prerequisites required by Littleton's ordinance are 
             arguably less onerous than those in FW/PBS, Littleton's ordinance similarly 
             does not specify a time limit within which the City must complete them.  We 
             therefore consider whether they render Littleton's ordinance unconstitutional 
             for failure to satisfy the first requirement of Freedman and FW/PBS.
                  Every retail business in Colorado must obtain a sales-tax license.  Colo. 
             Rev. Stat.   39-26-103.  Because this requirement is not specific to adult 
             businesses, it is irrelevant to the constitutionality of the licensing ordinance at 
    	 issue in the present case.  The City does not argue, however, that the other two 
             requirements are similarly applicable to all businesses, and we therefore 
             presume that they are specific to adult businesses.  Littleton's ordinance 
             provides no assurance that the City will promptly act on a pre-application 
             request for a certification of zoning compliance or for fingerprinting or 
             photography.
                  During oral argument of the present case, counsel for the City offered to 
             make a "judicial admission" on behalf of the City that "if the Zoning Official 
             doesn't act, the application can be complete without his statement."  Littleton's 
             ordinance, however, explicitly states that the "City Clerk shall not accept any 
             application that is not complete in every detail."  Littleton, Colo., City Code 
               3-14-5.  Such details presumably include the provision of the Zoning 
             Official's letter as well as the requirements of photography and fingerprinting 
             by the Police Department.   By interpreting the ordinance as allowing for the 
             submission of an incomplete application in the event of delay by the Zoning 
             Official, appellee's counsel is stating a legal conclusion, and courts are 
             reluctant to treat opinions and legal conclusions as judicial admissions.  See 
             MacDonald v. General Motors Corp., 110 F.3d 337, 341 (6th Cir. 1997); Glick 
             (9)       Littleton's original ordinance required all principal owners, managers 
             and employees to be photographed and fingerprinted.  Littleton, Colo., 
             Ordinance 27 (1993).  In 2001, the City eliminated the requirement with 
             respect to employees, but specified that managers, general partners and (in the 
             case of a corporation) the president of the corporation must be photographed 
             and fingerprinted.  Littleton, Colo., Ordinance 13 (2001).  No time limit for 
             the fingerprinting and photography was specified either in the original 
             ordinance or in the amended ordinance.
              
             v. White Motor Co., 458 F.2d 1287, 1291 (3d Cir. 1972); New Amsterdam Cas. 
             Co. v. Waller, 323 F.2d 20, 24 (4th Cir. 1963).  "A matter as important as the 
             constitutionality of a state statute should not be decided on the basis of an advocate's 
    	 concession during oral argument."  Virginia v. Am. Booksellers 
             Ass'n, 484 U.S. 383, 398 (1988) (Stevens, J., concurring in part and dissenting 
             in part).
                  Moreover, Freedman requires that either a "statute or authoritative 
             judicial construction" must specify the time limit within which the license 
             must be issued or denied, 80 U.S. at 5859, and there is nothing in Justice 
             O'Connor's opinion suggesting that this requirement was changed in FW/PBS. 
             Federal courts "lack jurisdiction authoritatively to construe state legislation." 
             United States v. Thirty-Seven (37) Photographs, 402 U.S. 363, 369 (1971). 
             Only if a state law is "readily susceptible" of an interpretation may the federal 
             courts subject it to a narrowing construction, and "we will not rewrite a state 
             law to conform it to constitutional requirements."  Am. Booksellers Ass'n, 484 
             U.S. at 397 (majority opinion).  Because Littleton's ordinance is not "readily 
             susceptible" to the interpretation offered by the City-to the contrary, it is 
             readily susceptible to the opposite interpretation-much as we are tempted, we 
             cannot decide this case on the basis of Littleton counsel's oral argument offer.
                  Although the Colorado Supreme Court upheld a similar requirement that 
             a zoning permit must accompany the application for a sexually-oriented-
             business license in City of Colo. Springs v. 2354, Inc., 896 P.2d 272, 28182 
             (Colo. 1995), a separate Zoning Ordinance in that case required that a zoning 
             administrator "approve or deny a zoning permit application within ten working
              
             days of the submittal."  Id. at 282.  Counsel for the City implicitly conceded at 
             oral argument that no such time limit is present in this case.  Because no time 
             limit is specified in the ordinance or by authoritative judicial construction, we 
             hold that the subject ordinance's requirement that a letter from the Zoning 
             Official accompany the application, along with the fingerprinting and 
             photography requirements, are unconstitutional for failure to specify a time 
             limit within which the City must act.(10)  See FW/PBS, 493 U.S. at 227.  To the 
             extent that the City's motion for summary judgment on this point was granted 
             and ZJ's motion for partial summary judgment was denied, the order of the 
             district court is reversed.
                                             C
                  Having held that Littleton's ordinance fails to meet the first test of 
             FW/PBS, we must decide whether the unconstitutional provisions are severable. 
             Under Colorado law, a section of a legislative enactment is severable if the 
             remaining portion of the statute is autonomous and the legislature's will in 
             passing the entire statute is not thwarted by the excision.  City of Lakewood v. Colfax 
    	 Unlimited Ass'n, 634 P.2d 52, 70 (Colo. 1981) (en banc).  Utilization 
             of a severability clause creates a presumption that the legislature would have 
             been satisfied with the remaining portions of the enactment.  Id.  A provision 
             will not be held severable, however, if the remaining enactment is "so 
             incomplete or riddled with omissions" that it lacks coherence.  Id.
                  At issue in the present case is an ordinance that contains a severability 
             clause, both in its original version and in the amended version.  Littleton, 
             Colo., Ordinance 13,   8 (2001); Littleton, Colo., Ordinance 27,   8 (1993). 
             More importantly, other requirements of the ordinance do not depend upon the 
             constitutionally suspect pre-application requirements for coherence or 
             consistency, and the purpose of the ordinance is not thwarted by their excision. 
             As a result, we conclude that the pre-application licensing provisions of the 
             ordinance are severable.
                                             D
                  Because other provisions of Littleton's ordinance, if constitutional, may 
             be enforced without the pre-application requirements, we must decide whether 
             the remainder of the ordinance is constitutional.  Thus we consider the "prompt 
             judicial review" requirement adopted by the Supreme Court in FW/PBS, 493 
             (10)       As noted above, this defect in Littleton's ordinance cannot be cured by 
             "judicial admission," as the City's counsel suggests.  Appropriate procedures 
             under Colorado law for the amendment of a city ordinance must be followed.  It 
             is not our role to sit as a party to negotiations concerning the implementation 
             of the City's code.  Littleton's ordinance can easily be amended to state that an 
             application may be submitted without zoning approval, fingerprinting, or 
             photography if a good faith request is not acted on by the Zoning Official or 
             the Police Department within a specified brief time period.
              
             U.S. at 228.  ZJ argues that "prompt judicial review" requires the City to 
             provide a "prompt decision" from the courts as to whether a license should 
             have been granted or denied.  (Appellant's Br. at 23.)  According to the City, however, 
    	 "prompt judicial review" means only that there must be "`the 
             possibility' or `an avenue' for prompt judicial review," and there need not be a 
             "judicial determination" within a short period of time.  (Appellee's Am. Resp. 
             Br. at 47.)
                  The circuits are divided over this question.  Some have held that "prompt 
             judicial review," at least with regard to licensing decisions, requires only that 
             the government provide prompt access to the courts.  See, e.g., Boss Capital, 
             Inc. v. City of Casselberry, 187 F.3d 1251, 125657 (11th Cir. 1999) 
             (concluding that "access to prompt judicial review is sufficient for licensing 
             decisions"); TK's Video v. Denton County, 24 F.3d 705, 709 (5th Cir. 1994) 
             (same); see also Graff v. City of Chicago, 9 F.3d 1309, 1324 25 (7th Cir. 
             1993) (en banc) (opinion of Manion, J.) (noting the availability of the 
             common-law writ of certiorari and finding this procedure sufficient under 
             FW/PBS); Jews for Jesus v. Mass. Bay Trans. Auth., 984 F.2d 1319, 1327 (1st. 
             Cir. 1993) (implying that access is sufficient).  Others have concluded that 
             "prompt judicial review" requires a prompt judicial resolution of license 
             denials.  See Nightclubs, Inc. v. City of Paducah, 202 F.3d 884, 89293 (6th 
             Cir. 2000); Baby Tam & Co. v. City of Las Vegas, 154 F.3d 1097, 1101 02 
             (9th Cir. 1998); 11126 Baltimore Boulevard, Inc. v. Prince George's County, 
             58 F.3d 988, 100001 (4th Cir. 1995).  
     
                  Access to prompt judicial review was selected as the appropriate standard 
             by the Eleventh Circuit in Boss Capital, 187 F.3d at 1255 57.  That case 
             enunciates two principal bases in support of its holding that mere access is 
             sufficient in adult-business licensing cases.  First, Boss Capital holds that 
             Justice O'Connor modified the second Freedman requirement relating to 
             judicial review in the adult-business licensing context.  Id. at 125556. 
             Second, Boss Capital reasons that this interpretation of FW/PBS is appropriate 
             given the difference between censorship cases and licensing cases.  Id. at 
             1256 57.
                  Focusing on Justice O'Connor's language, the Eleventh Circuit points out 
             that Justice O'Connor uses different terminology than Justice Brennan in 
             describing Freedman's second requirement.  Id. at 1255 (citing FW/PBS, 493 
             U.S. at 22829).  Justice O'Connor's opinion holds that there must be "the 
             possibility of prompt judicial review" in the event a license is denied, FW/PBS, 
             493 U.S. at 228 (opinion of O'Connor, J.) (emphasis added), and states that the 
             Dallas ordinance failed to provide an "avenue for prompt judicial review," id. at 
             229 (emphasis added).  Later, the requirement is characterized by Justice 
             O'Connor as "the availability of prompt judicial review."  Id. at 230 (emphasis 
             added).  In contrast, Justice Brennan's concurrence states that a "prompt 
             judicial determination must be available."  Id. at 239 (Brennan, J., concurring) 
             (emphasis added).
     
                  Justice O'Connor's language could arguably mean that the FW/PBS Court 
             modified the second Freedman requirement in the context of licensing cases. 
             See Boss Capital, 187 F.3d at 125556 (relying partially on the difference of 
             language to distinguish Freedman from FW/PBS).(11)  It is by no means clear, 
             however, that Justice O'Connor intended to change the meaning of the "prompt 
             judicial review" requirement.  First, when Justice O'Connor refers to "prompt 
             judicial review," she cites to Freedman, which unequivocally stated that the 
             procedure must "assure a prompt final judicial determination."  380 U.S. at 59; 
             see also 11126 Baltimore Boulevard, 58 F.3d at 999 (discussing this point). 
             Other decisions following Freedman have used the phrase "prompt judicial 
             review" to indicate a prompt judicial determination, albeit in a censorship context.  
    	 See 11126 Baltimore Boulevard, 58 F.3d at 1000 (listing several 
             Supreme Court cases).  Moreover, elsewhere in her opinion in FW/PBS, Justice 
             O'Connor states that the "first two safeguards" provided for by Freedman are 
             "essential."  FW/PBS, 493 U.S. at 228.  Although Justice O'Connor inevitably 
             qualifies the prompt judicial review requirement by referring to the 
             "possibility," "availability," or "avenue" of such review, such qualification most 
             likely amounts to an acknowledgment that it is up to the plaintiff to decide 
             whether or not to seek judicial review.  This language does not necessarily 
             indicate any intent to weaken the second Freedman requirement.
                  Parties always have access to the courts.  See FW/PBS, 493 U.S. at 248 
             (White, J., dissenting) ("[N]o one suggests that licensing decisions are not 
             subject to immediate appeal to the courts."); Baby Tam, 154 F.3d at 1101 ("[A] 
             person always has a judicial forum when his speech is allegedly infringed." 
             (quoting Graff, 9 F.3d at 1324)).  Judicial review is available regardless of 
             whether an applicable state court procedure is expressly mentioned in the 
             ordinance.  In order to have "prompt judicial review," however, a party 
             necessarily must be able to obtain a decision, for "without a decision, the most 
             exhaustive review is worthless."(12)  Baby Tam, 154 F.3d at 110102.  Thus,
             
    
    
             (11)       If the O'Connor opinion did modify Freedman's "prompt judicial 
             review" requirement for the licensing context, then it arguably struck down the 
             ordinance at issue in FW/PBS on a narrower ground (failure to provide prompt 
             access to judicial review) than the Brennan concurrence would have (failure to 
             provide the prompt judicial determination required by Freedman).  If that is the 
             case, then the O'Connor restatement of the "prompt judicial review" 
             requirement might well state the law, at least in the context of adult business 
             licensing.  See Marks v. United States, 430 U.S. 188, 193 (1977) ("When a 
             fragmented Court decides a case and no single rationale explaining the result 
             enjoys the assent of five Justices, the holding of the Court may be viewed as 
             that position taken by those Members who concurred in the judgments on the 
             narrowest grounds." (quotation omitted)).  Whether this would constitute the 
             narrowest ground for decision is debatable, however.  See 11126 Baltimore 
             Boulevard, 58 F.3d at 999 & n.15 (arguing that, if Justice O'Connor modified 
             the Freedman requirement, this was not the narrowest ground for decision). 
             Because we conclude that Justice O'Connor did not modify the second 
             Freedman requirement in the licensing context, we need not decide which 
             ground for decision in FW/PBS was the narrowest.
             (12)       Baby Tam draws an analogy to baseball.  Judicial review without a 
             decision "would be like throwing a pitch and not getting a call.  As legendary 
             major league umpire Bill Klem once said to an inquisitive catcher: `It ain't nothin' 
    	 till I call it.'  This is also true of judicial review.  Until the judicial 
             officer makes the call, it ain't nothin'.'"  154 F.3d at 1102.
              
             Justice O'Connor's "avenue for prompt judicial review" requirement in a First 
             Amendment context makes far more sense if it is understood to mean a prompt 
             final judicial determination.
                  The Eleventh Circuit further points out in Boss Capital that Freedman and 
             the line of cases following it can be distinguished from adult-business 
             licensing cases on the grounds that they involved censorship rather than 
             licensing.  Justice O'Connor held in FW/PBS that licensing schemes do not 
             involve "the grave `dangers of a censorship system,'" and therefore "the full 
             procedural protections set forth in Freedman are not required."  493 U.S. at 
             228 (citation omitted).  As the Eleventh Circuit notes, adult-business licensing 
             schemes primarily involve "mundane and ministerial factors," such as the 
             general qualifications of each applicant.(13)  Boss Capital, 187 F.3d at 1256.  In 
             contrast, censorship cases involve a highly subjective judgment about the 
             nature of the suspect material.
                  In addition, the Eleventh Circuit notes, "unlike movie distributors who 
             might show a given film in hundreds of theaters around the country," applicants for 
    	 adult-business licenses arguably have a greater incentive "to stick it out and 
             see litigation through to its end."  Id. at 1256.  Freedman's rationale therefore 
             arguably makes less sense in the licensing context, and Boss Capital concludes 
             that the need for a prompt judicial decision is therefore "less compelling."(14) 
             See Boss Capital, 187 F.3d at 125657 (arguing that access to prompt judicial 
             review is sufficient for licensing cases).  Because the ordinance in dispute 
             contained an explicit judicial review provision, the Eleventh Circuit held it 
             constitutional.  Id. at 1255, 1257.
                  Boss Capital draws a rational distinction between licensing cases and 
             censorship cases.  The purpose of Justice O'Connor's language distinguishing 
             between these two categories, however, is most logically understood as an 
             attempt at explaining why Freedman's third safeguard-that the burden of going 
             to court and the burden of proof must be on the censor-is not appropriate to 
             the licensing context.  See FW/PBS, 493 U.S. at 229 30 (concluding that the 
             third Freedman requirement does not apply to licensing cases).  If Justice
             (13)       Littleton's ordinance, for example, lists eight specific reasons to deny 
             a licensealthough the ordinance does not explicitly state that this list is 
             exclusiveand these reasons do not involve discretion on the part of the 
             licensing official.  Littleton, Colo., City Code  3-14-8.  
             (14)       Analyzing the constitutionality of a permit requirement for a public 
             forum, the Supreme Court has recently held that an ordinance that gives no 
             discretion to the licensing official does not threaten to stifle free expression. 
             See Thomas v. Chi. Park Dist., 122 S. Ct. 775, 780-81 (2002).  However, 
             Thomas distinguishes FW/PBS on the grounds that "it involved a licensing 
             scheme that target[ed] businesses purveying sexually explicit speech," id. at 
             780 n.2 (quotation omitted), and the Court did not overrule its earlier decision 
             that the first two Freedman requirements must be applied in adult-business 
             licensing cases.
              
             O'Connor had intended to adopt a different judicial review requirement for 
             licensing cases, she could have done so explicitly, just as she explicitly 
             rejected the burden-shifting requirement.
                  Other circuits have held that the judicial review requirement of Freedman 
             was not altered by FW/PBS.  As the Sixth Circuit notes, Justice O'Connor "gave 
             no indication that she was modifying the second requirement of prompt judicial 
             review" in the licensing context.  Nightclubs, 202 F.3d at 893.  According to 
             the Ninth Circuit, the FW/PBS plurality "took issue only with Freedman's 
             requirement that the censor bear the cost of going to court to obtain judicial 
             review; otherwise, FW/PBS offered nothing different from Freedman's concept 
             of what `judicial review' meant."  Baby Tam, 154 F.3d at 1102; see also 11126 
             Baltimore Boulevard, 58 F.3d at 999 (reaching the same conclusion).  If the 
             Court adopted the Freedman requirement without modification in FW/PBS, then 
             the distinction between licensing and censorship is not relevant here. 
                  Even if the rationale behind Freedman is specific to censorship cases, 
             there is an equally valid rationale for requiring prompt judicial review in adult-
             business licensing cases.  Although adult-business licensing ordinances are 
             technically considered "content-neutral," ZJ Gifts D-2, L.L.C. v. City of 
             Aurora, 136 F.3d 683, 68688 (10th Cir. 1998), they are distinguishable from 
             other content-neutral time, place, and manner restrictions insofar as they target 
             "businesses purveying sexually explicit speech."  Thomas v. Chi. Park Dist.,
              
             122 S. Ct. at 780 n.2 (2002) (quoting FW/PBS, 493 U.S. at 224).  A licensing 
             official may have little or no discretion in reviewing an application, but he or 
             she may be tempted nonetheless to overstep the bounds of the ordinance.
                  Adult businesses are controversial, and the possibility exists that 
             licensing officials might allow their personal views on the morality of sexually 
             explicit entertainment to sway a decision on an application.  Given the strong 
             feelings that adult businesses can engender, there must be a prompt judicial 
             determination to ensure that licensing officials do not exceed their authority 
             under the ordinance in their zeal to protect the local community.  ZJ sells 
             sexually explicit magazines and videocassette tapes, which are presumptively 
             protected by the First Amendment, see FW/PBS, 493 U.S. at 224, and the 
             danger that an ordinance like Littleton's may be improperly used as a 
             subterfuge for censorship is too great to overlook the necessity for a prompt 
             judicial determination.
                  In short, we are not persuaded by those circuits that have concluded that 
             mere "access" to judicial review is sufficient in licensing cases.  Following the 
             Fourth, Sixth and Ninth Circuits, we hold that, in the event that an adult-
             business license is denied, FW/PBS requires a prompt final judicial decision 
             regarding the validity of the denial.  "[A] theoretical possibility of expeditious 
             judicial review is not constitutionally sufficient."  Nightclubs, 202 F.3d at 892. 
              "While we trust state courts to exercise due diligence, we cannot be sure that a
              
             state judge .  .  . toiling under a busy docket, will conduct a hearing and render a 
             decision in a prompt manner."  Id.  Prompt judicial review, including a prompt 
             final decision, must be assured in all First Amendment licensing cases in order 
             for the second requirement of Freedman and FW/PBS to be satisfied.  What 
             constitutes a prompt judicial determination in the adult-business licensing 
             context is to be determined by reference to the Supreme Court's jurisprudence 
             following Freedman.  See, e.g., Southeastern Promotions, Ltd. v. Conrad, 420 
             U.S. 546, 56162 (1975) (holding that a judicial review process lasting more 
             than five months was not prompt).
                  Littleton's ordinance allows a party whose license has been denied to 
             appeal to the Colorado district court under Colorado Rule of Civil Procedure 
             106(a)(4).  This Rule allows an adverse decision regarding the license to be 
             given expedited review in the trial court's discretion.  2354 Inc., 896 P.2d at 
             284 (citing Colo. R. Civ. P. 106(a)(4)(VIII)).  Because this Rule does not 
             assure that license decisions will be given expedited review, however, it does 
             not save Littleton's ordinance.  Accordingly, the order of the district court 
             granting summary judgment for the City is reversed to the extent that it held 
             the judicial review procedure to be constitutionally sufficient.
                                             V
                  Finally, ZJ attacks the location restrictions in Littleton's ordinance as 
             unconstitutional because they do not provide reasonable alternatives of
              
             communication, as required by City of Renton v. Playtime Theatres, Inc., 475 
             U.S. 41 (1986).(15)  It is the City's burden to demonstrate that its ordinance 
             meets this requirement.  See ZJ Gifts, 136 F.3d at 688.
                  Renton considered a local ordinance that restricted the location of adult 
             businesses.  475 U.S. at 44.  Content-neutral zoning ordinances, the Court held, 
             are permissible so long as "reasonable alternative avenues of communication" 
             are left open, id. at 53, a question that is answered through an analysis of how 
             much land is available in which adult businesses may be located under the 
             zoning system, id. at 5354.  In undertaking that analysis, the courts must 
             examine what land is actually available, but also must keep in mind that adult 
             businesses must "fend for themselves in the real estate market, on an equal 
             footing with other prospective purchasers and lessees."  Id. at 54.
                  How much land is sufficient to constitute "reasonable alternative avenues 
             of communication" is a question that the Renton Court left open.  In Renton, the 
    	 ordinance left "520 acres, or more than five percent of the entire land area 
             of" the city, open for adult businesses, with the land "in all stages of 
             development from raw land to developed, industrial, warehouse, office, and 
             shopping space that is criss-crossed by freeways, highways, and roads."  Id. at 
             53 (quotation omitted).  The Renton Court determined that the ordinance 
             "easily meets" the requirement of providing a "reasonable opportunity to open 
             and operate an adult theater within the city."  Id. at 54.
                  Under Littleton's ordinance, there are approximately one-hundred acres 
             of land that are within industrial zones and outside the minimum distance from 
             nearby schools, day care centers, and correctional facilities.(16)  This land 
             constitutes between 1.2 and 1.3% of the total acreage of the City of Littleton. 
             At least one other court of appeals has found this proportion of land to be 
             sufficient under Renton.  See Lakeland Lounge of Jackson, Inc. v. City of 
             Jackson, 973 F.2d 1255, 1260 (5th Cir. 1992). 
    
             (15)       In its reply and supplemental briefing, ZJ argued that the location 
             restrictions in Littleton's ordinance should be viewed as "content-based" 
             restrictions on speech subject to strict scrutiny.  In particular, ZJ argues that 
             the recent Supreme Court decision in Thomas, 122 S. Ct. 775 (2002), and 
             Justice Kennedy's opinion in City of Los Angeles v. Alameda Books, Inc., 122 
             S. Ct. 1728, 1739 (2002) (Kennedy, J., concurring in the judgment), support 
             this claim.  This court, however, has previously held that a nearly identical 
             ordinance should be reviewed as a "content-neutral" regulation subject to 
             intermediate scrutiny.  See ZJ Gifts, 136 F.3d at 686-88.  We see nothing in 
             either Thomas or Alameda Books that requires reconsideration of our 
             conclusion as to the applicable standard of review.
             (16)       ZJ argues that some of these parcels are unavailable because portions 
             of the parcels are within five-hundred feet of schools, day care centers, and 
             correctional facilities.  However, as the record shows, the majority of these 
             parcels are outside the distance limits.  Under Littleton's ordinance, the 
             distance limits are only violated if the exterior wall of the structure in which 
             the adult business is located is within the minimum distance from the 
             neighboring use.  Thus, these parcels are available for use by an adult business 
             as long as the business locates in the portions of the parcels where such uses 
             are permitted.
              
                  ZJ argues that portions of this land are unavailable because specific 
             parcels are (1) currently occupied by large-scale manufacturing uses, see 
             Topanga Press, Inc. v. City of Los Angeles, 989 F.2d 1524, 153132 (9th Cir. 
             1993), or (2) currently owned by governmental entities, see Centerfold Club, 
             Inc. v. City of St. Petersburg, 969 F. Supp. 1288, 1305 (M.D. Fla. 1997).  
                  First, we disagree with the notion that warehouses and other large-scale 
             manufacturing uses must be excluded per se from any calculation of whether 
             there is sufficient land for adult business uses.  In Renton itself the Supreme 
             Court noted the diversity of property that was available for adult business use 
             under the ordinance-"industrial, warehouse, office, and shopping space," 
             Renton, 475 U.S. at 53 (emphasis added)-in concluding that there was 
             sufficient land available.  Similarly, Littleton's ordinance leaves a diversity of 
             different types of properties available for use by an adult business, including 
             large-scale manufacturing and warehouse uses.  Under Renton, there is no need 
             to exclude those uses from our analysis.(17)  While it may indeed be more 
             difficult and more expensive for an adult-business owner to acquire and convert these 
    	 types of properties, there is no requirement that those businessmen must 
             "be able to obtain sites at bargain prices."  Id. at 54.
                  As for inclusion of the government-owned properties, we need not decide 
             whether that is permissible under the Renton analysis.  Even excluding those 
             parcels that are government-owned according to evidence introduced by ZJ, 
             there is sufficient property zoned for adult business uses to meet the 
             requirements of Renton.  ZJ submitted evidence identifying only one specific 
             property-the Littleton City Shops between Belleview Avenue and Prentice 
             Avenue, constituting twelve acres-as being owned by the government.  Other 
             properties mentioned by ZJ in its brief-a fire training center, a nature area, 
             and the Arapahoe County Government Center-are not identified by parcel, nor 
             does ZJ provide any information as to their total acreage.  However, even 
             giving ZJ the benefit of the doubt as to these additional properties, based on 
             the information we can glean from the record, removing these properties would 
             only reduce the total available area by approximately ten acres.(18)  Thus, the
             (17)       We add that we do not address a situation where all or nearly all 
             properties consist of large-scale manufacturing and warehouse uses, such that 
             the diversity of land uses described in Renton does not exist.  In such a 
             situation, the municipality may be "effectively denying" adult businesses "a 
             reasonable opportunity to open and operate."  Renton, 475 U.S. at 54.
             (18)       In reaching this conclusion, we draw the following inferences in ZJ's 
             favor:  Littleton's fire protection center and the abandoned city property are 
             located in an industrial zone that comprises approximately eight acres near the 
             intersection of Chenango and Vallejo Streets.  We assume that all of those 
             properties were used by both the fire protection center and the abandoned city 
             property, and we remove them from our analysis.  As for the Arapahoe 
             Government Center, ZJ relies on the City's maps in the record as evidence 
             regarding its location on "South Crestline Avenue."  We can find only an 
             ambiguous reference for a parcel south of West Crestline Avenue, whichappears to occupy 
    	 about two acres of the industrial zones.  ZJ has provided us 
             with absolutely no information from which an inference can be drawn regarding 
             the specific location or acreage of Littleton's nature area.
              
             total area available excluding government properties would be about seventy-
             eight acres, or just under one percent of the total area of the City.
                  Moreover, excluding both the government properties to which ZJ objects 
             as well as those properties that are implicated by the minimum distance 
             requirements of the ordinance, the City has listed over twenty sites within the 
             industrial districts that its real estate expert stated would be available for adult 
             businesses.  Given the small population of Littleton (forty-thousand people), 
             and the fact that ZJ is the only adult business that is currently located in 
             Littleton, this is a sufficient number of available sites.  See Diamond v. City of 
             Taft, 215 F.3d 1052, 1058 (9th Cir. 2000) (holding seven available sites 
             sufficient where only one business sought to locate within the municipality), 
             cert. denied, 531 U.S. 1072 (2001);(19) see also Boss Capital, 187 F.3d at 1254 
             (listing factors to be considered in analyzing whether there are sufficient sites for  
    	 adult businesses, including geographical size of the locality, location of 
             sites, number of adult businesses currently operating or seeking permission to operate,  
    	 and population).  We conclude that the ordinance meets the 
             requirements of Renton,(20) and the section of the district court order dealing 
             with the location requirements of Littleton's ordinance is affirmed.
                                             VI
                  In sum, we conclude that ZJ has standing to challenge the pre-application 
             and location requirements of the ordinance and the judicial review procedure. 
             ZJ lacks standing, however, to challenge the ordinance as vague, attack the 
             ordinance's license revocation and suspension provisions, or challenge the age 
             and criminal history restrictions in the ordinance.  As to the merits of ZJ's 
             challenge, we hold that the judicial review procedure and pre-application 
             requirements of Littleton's ordinance are unconstitutional, but that the location 
             requirements of the ordinance are constitutional.
             (19)       Where an adult-business zoning regulation prohibits the location of 
             one adult business within a minimum distance of another oneas Littleton's 
             ordinance doessome courts have required the analysis of the minimum 
             number of sites to take into account those spacing requirements, dramatically 
             reducing the potential number of sites.  See, e.g., Young v. City of Simi Valley, 
             216 F.3d 807, 821 n.13 (9th Cir. 2000).  ZJ has never argued that we should 
             incorporate the spacing requirements into our analysis, and given that ZJ is the 
             only adult business currently operating or seeking to operate in Littleton, such 
             an adjustment would be inappropriate in the first place.  See Diamond, 215 F.3d 
             at 1057-58.
             (20)       ZJ urges us to hold that the Colorado Constitution provides broader 
             protections than the United States Constitution in this context.  None of the 
             cases cited by ZJ in support of this proposition, however, involves a challenge 
             to adult-business licensing ordinances.  See Bock v. Westminister Mall Co., 
             819 P.2d 55, 56 (Colo. 1991) (discussing plaintiffs' right to distribute 
             political leaflets in a shopping mall); People v. Ford, 773 P.2d 1059, 1061 
             (Colo. 1989) (addressing the constitutionality of the Colorado obscenity 
             statute); People v. Seven Thirty-Five East Colfax, Inc., 697 P.2d 348, 353 
             (Colo. 1985) (same).  In analyzing a local ordinance regulating nude dancing, 
             the Colorado Supreme Court relied almost exclusively on federal cases in 
             determining that the ordinance did not violate the free speech protections of 
             either the federal or state constitutions.  See 7250 Corp. v. Bd. of County 
             Comm'rs, 799 P.2d 917, 924-28 (Colo. 1990) (en banc).  We have found no 
             evidence that in this particular field of free speech jurisprudence the Colorado 
             courts have interpreted the state constitution to provide greater protection than 
             the federal Constitution.
              
                  The judgment of the district court is AFFIRMED in part and 
             REVERSED in part.(21)
             
             
    
             (21)       We grant the City's motions to file additional supplemental 
             appendices.
             
    

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